Last Updated: October 15, 2019
Skywarpel Trading Limited, trading as “ABBYCAR” whose registered office is located at Boumpoulinas 11str, Nicosia, Cyprus (hereinafter referred to as (“we”, “us”, “our(s)”) is responsible for the processing of your personal data (i.e. any information that would allow us to identify you, either directly or indirectly) through our website, our rental stations, or through any other contact you may have with us.
We collect Personal Data that you provide on our websites, on third-party websites, on applications and offline in connection with any inquiries, reservations, rentals or purchases you make in relation to our services. We may collect your Personal Data directly or through our service providers, business partners, discount sponsors, licensees, advertisers and booking channel providers. For further details, see below:
TYPES OF INFORMATION COLLECTED (may include but not limited to):
- Personal Information: (name, age, date and place of birth, gender, address, email address, phone number, passport number, driving license or other ID photograph, credit score and history, criminal history)
- Rental Information: (payment card information, booking location, rental location, return location, preferences and usage information, charges incurred, purchase prices and details, itinerary information, data related to claims)
METHODS AND SOURCES OF COLLECTION
- Online: (our website, our offices, our mobile apps, our social network pages)
- calls to or from our reservation, customer service, emergency road-side assistance, customer contact or member care centers
- interaction with our various licensees, affiliates, and subsidiaries, including car sales and other businesses
- in-person at rental locations
- in-vehicle or in-equipment technology or through other telematic devices
- in connection with a reservation (even an abandoned or interrupted reservation), a rental of a vehicle or equipment, or your purchase of a vehicle or equipment
- reservations you make with us through licensees, travel agents or brokers, online or in-person
- transactions you complete with us, our licensees, and agents including options you take, charges you incur and any incidents or accidents that may occur
- when you join our membership programs
- CDP Sponsors or sponsors of promotion codes, affiliation, or special discount codes.
- consumer reporting agencies and other companies that have business relationships with us, such as our licensees’ affiliates and business partners, including airlines, hotels, and insurance companies
- Claims Management service providers (either affiliated directly with us, or operated by a third party)
Depending on the purposes for which we collect and use your Personal Data, as set out in this Policy, the Personal Data we collect from you may be required due to a statutory or contractual obligation, provided on a voluntary basis, or necessary for us to enter into a contract with you. If you do not provide your Personal Data to us this may result in disadvantages to you. In particular, we may not be able to rent to you. However, unless otherwise stated, not providing your Personal Data will not result in legal consequence for you.
Below we have set out the various purposes for which we process your Personal Data. We have also set out the legal grounds for the processing of your Personal Data for each purpose.
OPERATIONS AND SERVICES
We may use your Personal Data to provide you with the services or products you request from us and to perform other activities related to such services or products, including:
- to Confirm/Modify/Cancel your booking
- to correspond with you in relation to your booking or rental
- to verify your identity and to carry out credit and fraud prevention checks prior to releasing a vehicle to you at the start of your rental
- to manage your rental and/or invoice and/or any dispute or claims or recover any losses relating to your rental
- to manage any fines and penalties (this processing is either required by low or carried out to support our legitimate interests.
Legal grounds: to perform our contract with you or to take steps at your request prior to entering into a contract with you.
We may use your Personal Data to provide you with marketing information, special offers and promotions via various means, including e-mail, in accordance with applicable law.
Legal grounds: on the basis of your consent. You can unsubscribe from receiving such messages at any time by contacting us at the details at the Contacts Section below as well as the unsubscribe link in each e-mail message
NORMAL COURSE OF BUSINESS
We may also process your Personal Data and other information if such processing is necessary:
- to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process
Legal grounds: where it is necessary for compliance with a legal obligation to which we are subject.
- to protect the interests, rights, safety, or property of us or others
Legal grounds: where it is necessary for compliance with a legal obligation to which we are subject.
- to enforce any terms of service on our websites or the terms and conditions of any rental, purchase, or utilization
Legal grounds: for our legitimate interests, which are to protect us and enforce such terms of service or terms and conditions.
- as part of a business transaction where all or some of our assets are bought, sold, or otherwise transferred by act of law or contract
Legal grounds: for our and third parties’ legitimate interests.
- to operate our systems properly.
Legal grounds: for our legitimate interests, which are the proper running of our systems and our business in order to provide our products and services to you and other customers.
We may use in-vehicle data systems to collect data about the vehicle’s position, condition and performance during your rental. Use may include:
- to collect data relating the vehicle’s condition and performance during the rental to improve the accuracy of our billing processes on return of the vehicle
Legal grounds: for our legitimate interests to ensure accurate charging for your uses of the vehicle, including for fuel and damage, during your rental
- to collect data relating to the driver’s operation of the vehicle during the rental for safety, security and claims management reasons, including to contact the renter if the data suggests there is a security, safety or operational issue that we need to bring to your attention
Legal grounds: for our legitimate interests to enable us to defend and manage claims arising out of accidents involving the rental vehicle; to ensure we meet our safety and security obligations in relation to the vehicle and each rental
- to track the vehicle’s location throughout the duration of a rental in order to access such information solely where the driver is in breach of the rental agreement (by failing to return the vehicle on time or by driving into unauthorized territories) or to assist in the defense and management of claims following an accident involving the vehicle
Legal grounds: for our legitimate interests to protect our assets, enforce our terms and conditions and defend and manage claims
If you use our website, we may process your Personal Data as follows:
- Aggregated or anonymized information
We may share with other third parties aggregate or anonymized information about our website users, such as your use of this website or other websites, and the services provided on this website or other websites, as well as any rental, purchase, or utilization information.
If you participate in certain public features of our websites, apps, or social media websites/apps, please note that any information you or others voluntarily disclose through use of such features, becomes available to the public and/or other users whom you have designated. If you choose to provide access credentials to designated individuals, please be aware that any information you provide to us may be visible to such individuals. We are not responsible for the information that you or others choose to disclose publicly and such information is not subject to this Policy.
We may provide links to third-party websites, or may be linked to from third-party websites. Since we do not control third-party sites, and we are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing applicable third-parties with your information.
CATEGORIES OF RECIPIENT
We may share your personal data among ourselves, our agents, our licensees and other companies to provide services to you. Your personal data will be disclosed, where necessary and relevant:
- to authorized personnel within our company and to entities in our group and/or to entities in our group franchise network, or any person appointed
- by any of these entities for the purposes of fulfilling your rental booking and supplying associated services
- to third party IT service providers for technical purposes in order to help us provide you with our products and services
- to law enforcement bodies and other public and private sector bodies for the purposes of dealing with alleged, or actual, road traffic or driving offences and/or associated fines; and private parking companies dealing with alleged or actual breaches of contract
- for the management and update of a register of customers presenting certain risks to the vehicle rental business generally or to its staff
- to fraud prevention agencies who will use it to verify your identity and to prevent fraud and money-laundering
- to companies supplying operational support in relation to:
- delivery and collection of vehicles
- authentication of you and your driving license history
- insurers and solicitors that manage our insurance claims and/or debt recovery matters
Depending on the circumstances, certain recipients may be located in countries which have, or have not, been recognized by the European Commission as ensuring an adequate level of data protection. In the event your destination country is not recognized by the European Commission as having adequate levels of data protection you should be assured that we have put in place the appropriate safeguards to ensure that your personal data is protected in accordance with the requirements of the Data Protection Act 1998 and associated EU regulations.
RETENTION & SECURITY
We retain personal data about our customers for as long as we believe is necessary for the purposes for which it was collected, or unless otherwise allowed or required by law. We collect Personal Data for a number of purposes (see above) and may be required to retain it for legal (including tax) reasons for a period which is longer than the time we need or use the data for the purpose of providing our rental services to you. We maintain a data retention policy to cover all the Personal Data we retain across our systems. If you have any questions about the retention period applying to the Personal Data, we collect about you, please contact us in the details provided below.
Information is stored and accessed in various locations and cloud services. Servers which store information are primarily located in Greece and Europe, although storage may occur in other locations as well. We use reasonable administrative, technical, personnel, and physical measures
- to safeguard Personal Data against loss, theft, unauthorized use, disclosure, or modification
- to ensure the integrity of your Personal Data
To help us protect your privacy, you should maintain the secrecy of any logon IDs and passwords, Member numbers, or other identifiers or credentials you may have set up or were provided with in connection with your participation in or use of our products, services, or websites.
As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. If you have reason to believe that any account with us is no longer secure, you must immediately contact us.
We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative. Please do not include confidential information, such as your credit or debit card number or account passwords, in any e-mail or text you send to us or on any posting you make to a public area of a third-party social network page, especially since any such posting immediately becomes public. For a more secure way to communicate with us over the Internet, please click on the “Contact Us” link on our website.
- You have the right to request access to, review, and update your Personal Data covered by this Policy, and can request this by contacting us at the details set out in Section 6 below. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws. If you are a member of one of our membership or rewards programs, you may update the information in your member profile by logging into your applicable member profile.
- You also have the right to:
- request rectification of your Personal Data where the information that we hold about you is incorrect or incomplete
- object to the processing of your Personal Data for direct marketing purposes, including profiling to the extent it relates to direct marketing
- object to the processing of your Personal Data where our legal basis for that processing is that such processing is necessary for our legitimate interests, subject to any overriding legitimate grounds that we may have for the processing
- object to automated decision making (including profiling) in certain circumstances
- request erasure of your Personal Data in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for and there is no compelling reason for us to continue to process (or store) it
- request restriction of your Personal Data in certain circumstances, such as that we do not process certain of your Personal Data (other than merely by storing them) following a rental in circumstances where all matters relating to the rental have been completed and the data is being stored only to meet certain legal (e.g. tax) requirements
- receive (or ask us to transmit to another organization) your Personal Data that you have provided to us which we process by automated means where our processing is either based on your consent or is necessary for the performance of a contract with you.
- In addition, where we process your Personal Data on the basis of your consent, you can withdraw that consent at any time
You can make a request to us to exercise any of these rights by contacting us as set out in the Section Contacts below.
QUESTIONS & CHANGES
We do business in many countries and aim to comply with the privacy laws applicable to the Personal Data we collect and use. Should you have a concern or complaint about our handling of your Personal Data, you may contact us directly via the methods described below. We will work to respond and resolve your complaints in an expeditious manner. You also have the right to lodge a complaint with a competent data protection supervisory authority in your jurisdiction.
Please contact us by emailing email@example.com or writing to the address below if you have any questions, wish to exercise your rights of access, or seek other assistance as described above. We will work to respond and resolve your complaints in an expeditious manner.
Skywarpel Trading Ltd (ABBYCAR)
Data Protection Officer
15 Kimonos, Green Park
1057 Likavitos, Nicosia
We reserve the right to change this Policy at any time for any reason by posting revisions on this webpage. Such changes will be effective upon posting, but will not apply retroactively. Whenever we make a material change, we will note the date of such update in the introductory page above, and post a note on the home page of our applicable website.